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Case Study #2

Clear and accessible: Revamped complaint form for easier use

(See complete document here)




A national consumer advocacy organization aimed to improve the accessibility of its complaint form. They had learned, through customer feedback, that 20 per cent of users found the form challenging. This was particularly true for people whose first language was neither English nor French. 


I used an online readability tool to measure the reading grade level of the form and some of the writing techniques that can create barriers.


I used Plain Language writing techniques to reduce the reading grade level and the barriers to accessibility.


The result was a form with a reading grade level 3 grades lower than the original. There were also significant reductions in the number of barriers to accessibility like passive voice sentences and complex phrases.


The next step is to gather feedback from users of the revised form to see if the number of people who find the form challenging is reduced.


Full case study


The client: Commission for Complaints for Telecom-television Services (CCTS)


Canada has a national organization that deals with complaints from customers about telecommunications and television services – the CCTS (Commission for Complaints for Telecom-television Services) The service is free and independent. No one in the organization either regulates or offers any of these services.


The challenge: Improve accessibility of the CCTS complaint form


On May 23, 2023, CCTS announced that it was changing its services. Their goal was to make their service easier to understand and use. I was part of that process.


CCTS wanted their complaint form to be in plain language and they wanted as many people as possible to be able to use it. They approached me to review and edit their new form. They also gathered feedback from a wide array of customers and gave me a copy of that feedback.


The feedback showed that about 80% of survey respondents found it easy to file a complaint with CCTS. But about 20% found the process to be “somewhat easy” or not easy at all. Some test subjects complained that the language in the form and the directions for filling it out were too difficult for anyone who was not a native English or French speaker. Some noted that repetitive questions complicated the form. Others were not sure what information was required and what was optional.


The solution: An online readability tool and plain language


I did my own assessment of the form using Hemingway Editor. Based on the clean writing of American novelist Ernest Hemingway, this tool shows how complex your writing is. When you drop your text into the app it provides the following metrics:

  • grade level

  • use of passive voice

  • number of adverbs

  • number of phrases with simpler alternatives

  • number of sentences that are hard to read

  • number of sentences that are very hard to read


What I like about the app is that it gives me a snapshot of some of the things I should be looking for as a plain language editor. It is also a form of artificial intelligence, however, and so relies quite a bit on numbers of words per sentence and numbers of characters per word. So, a sentence that is “very difficult to read” is usually a sentence of 30 words or more. 


This means, as an algorithm, it can only point the way toward plain language by simplifying the writing. One tool in your plain language tool box. You can’t build a whole house with just a hammer and you can’t create a plain language document, online or in print, with just a readability AI. But it helps.


The results: Complaint form reads at a lower grade level, therefore is accessible to more users


The following table shows the Hemingway Editor results for the original complaint form and the plain language version:









The following chart shows the same data:










The next step: Get feedback from form users

The next step is to test the new version with people who use the complaint form. That’s because only the audience can say how well they can understand a document and use it.


I try to make the document as clear and usable as I can before bringing it to an audience to test. So, among other things, I shorten sentences, convert passive voice to active voice, and replace complex words and phrases with simpler ones. I also remove words and phrases that do not add meaning, which means taking out adjectives and adverbs. Often, that brings the document down to a lower grade reading level. All of this must be done without changing or diluting the meaning.




Grade level should never be your only metric for deciding whether or not a document is in plain language. However, it can be a good indicator, and a good place to start preparing a document for testing with your intended audience.


Many plain language professionals use the following grade-level guide to determine the type of information suitable for different audiences.


Grades 5 to 6

Information the public needs to know, including marginal readers and people who use English as a second language

Grades 7 to 9

Information that introduces the general public to new terms and concepts or specialized subject matter

Grades 10 to 11

Specialized information for an audience of fluent readers who have time to focus on the material

Grades 13 to 14

Specialized information for an audience that is well-informed on the subject and has time to focus on the material 


**Source: Clear Language and Design


Note that lower grade reading levels are always acceptable as long as the language flows and you do not appear to be talking down to your audience. No one ever complained that something was too easy to read or understand.

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